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Sanctions – Iran – Update on US withdrawal from the JCPOA

16 May 2018

Further to President Trump’s announcement on 8 May that the US would withdraw from the JCPOA and the two periods for winding down business activities connected to sanctioned trade with Iran (as we outlined in our News Alert of 9 May 2018, click here), we have now received further clarification from US lawyer, Mr William Juska of Freehill Hogan & Mahar LLP, that OFAC have informally advised that US secondary sanctions (i.e. sanctions that affect non US entities/persons) are now in effect. Furthermore and importantly for non-US entities/persons, that OFAC has indicated informally that any new Iran-related transactions (entered into after 8 May), if it were a sanctionable activity under the US secondary sanctions, could result in penalties being imposed. Mr Juska advises “in informal discussions OFAC has indicated that penalties could be imposed on sanctionable activities entered into after May 8, even if they are concluded within the applicable wind-down period. It is recommended that any party considering entering a new Iran-related transaction after May 8, which transaction would be contrary to the secondary sanctions, give careful consideration to the possibility that sanctions could be imposed by OFAC, and consider seeking guidance from OFAC before entering any such transaction.”

Whilst this is only informal advice from OFAC, in the absence of contrary information/clarification from OFAC, the Club recommends that Members/Assureds follow this advice in relation to any new trade involving Iran.

A full outline of the latest position, including details of the winding down periods and recommendations concerning new Iran-related business can be accessed in the US lawyers client alert available here.

The US Department of the Treasury FAQs (which serve as the License for trade during the winding down period), issued on 8 May, are available here. To access the US Department of the Treasury’s overview of the Iran sanctions, including links to FAQs, Guidance, Licences and legal authorities, click here.